## Security Happeo privacy & security procedures --- ## Introduction *Happeo is a digital workplace integrated with* *Google’s G Suite. The goal of Happeo is to make* *your company more efficient and productive by* *solving the most common collaboration and* *communication barriers. We do this with data* *security at the core of our product and our* *business.* --- ## CONTENTS ## Table of contents * Your security comes first * What data do we collect? * Information from other sources 4 6 7 * How do we use the collected information? 9 * Frequently asked questions about Happeo Security 12 * Privacy policies 16 --- **SECURITY** # Your security comes first **Security at core** Happeo is developed with Google technology, operating on one of the world’s most secure and eliable cloud infrastructures. It is continuously monitored to protect your data 24/7. With Google’s cloud technology your data is distributed across multiple data centers to make sure no incident can affect your business. --- ## Personal information We use your personal information only for improving the content and the user experience of Happeo. By using our service, you agree to the collection and the use of information in accordance with this policy. ## General Data Protection Regulation (GDPR) The EU General Data Protection Regulation (GDPR) is designed to strengthen the rights that EU individuals have over their data, seeking to unify data protection laws across Europe. We are fully GDPR compliant and remain dedicated to taking care of personal data responsibly. --- **SECURITY** # What data do we collect? When you use Happeo, you trust us with your data. It is very important for us to have transparency of what information we collect from you and how are we using it to improve your user experience within Happeo. ## User provided information We collect information such as your username and email address when you register to Happeo or communicate with our customer service team, and send us emails. We also collect logs in our application, which may include your: • IP address, and/or • browser information. --- When providing us this information, you consent that your information is being collected, used, disclosed, and stored by us, according to the Happeo Security Policy. **SECURITY** # Information from other sources We collect data from the following sources and store it within our Happeo database so we can give you the best experience when using the Happeo service: • Google G Suite User Directory (providing identity, improving search and ACL) • Organisation information (included with the directory user) • Directory Groups (improving search and enabling ACL) --- There is also a possibility to improve search by collecting data from old Google Sites text content. However, this is fully optional and off by default. We collect user data because it helps to provide fast search capabilities, identity and better overall usability to users. The data collected can be, but not limited to; • Analytics, for anonymous tracking of service used for service improvements • Search queries, for organisation based predictions ## Cookies Cookies are used to identify users. If you prevent the usage of cookies, Happeo may not work as intended. ## User content Happeo allows you to post and upload information, text, graphics, and other material. The content posted by you is your “user content”. User content can be shared with others but its ownership remains with you. When you share something in Happeo, others may see, use, or share it. --- **SECURITY** # How do we use the collected information? We use the collected personal information only to: • improve Happeo, its usability and user experience • send system alert messaging • enforce compliance with our Terms of Use and applicable law • provide better customer support • protect the rights and safety of you, our customers, users, third parties and our own • meet legal requirements • provide information to representatives and advisors • prosecute and defend a court, arbitration, or similar proceeding • communicate with you about your account --- • keep your information secured in the unlikely case of a sale, a merger, a consolidation or an acquisition ## Log file We collect information that your browser sends whenever you visit Happeo (“Log Data”). This Log Data may include information such as: • IP address, • browser type • browser version • Happeo pages you have visited • time and date of your visit • time spent in our service • other statistics ## Security Happeo development team has a history of handling customer and user data. The security policies are reviewed monthly at minimum, and adjusted as needed. --- ## We keep our homebase secured Our personnel, regular employees and independent contractors, understand and follow Happeo security policy. Upon termination of work at Happeo, all access to Happeo systems is removed immediately. Happeo is a service provided by Universe Company Oy and its affiliates. Universe Company Oy is headquartered in Helsinki, Finland. ## Infrastructure Happeo is hosted in Google Cloud Platform (GCP) and adheres to all implementation best practices. A lot of questions about infrastructure can be answered by pointing to the Google Cloud Platform security page and security white paper. --- **SECURITY** # Frequently asked questions about Happeo Security *Does Happeo collect, store, access, handle or otherwise have access to* *information directly or indirectly related to customer company’s candidates,* *employees, client's employees or representatives?* Yes. Happeo enables, among other things, the search of other people in an organisation. The data that provides the user search and user profiles is synchronized from G Suite. These user profiles are admin managed and usually synchronized from HR systems or LDAP. This data is used to provide a user friendly search and user profiles. # Happeo synchronizes the following user related data from G Suite: --- ## User rich profiles: • User Google ID • User name • User emails • User phone numbers • User addresses • User organisation profile (title, cost center, manager, address) *Does Happeo have a documented data protection policy?* Yes. You can see our privacy policy here. *How is Happeo’s data protection policy implemented?* Happeo is extremely conscious of the data it holds and who can access the restricted data. Only a selected few have direct access to any sensitive customer data in Happeo and this access is only exercised when supporting customers. Personnel who have access to Happeo data go through a data protection training where they are educated on; • what kind of data is accessible --- • what are the developer responsibilities • what are our legal requirements and restrictions related to customer data This training is gone through with every employee regardless if they have access to customer data or not, and repeated when an employee gains access to customer data. *What training does Happeo provide to its employees, consultants,* *subcontractors, and other third party service providers who have access to* *Personal Data or Sensitive Data?* Only our direct employees have access to customer data, unless there’s a specific need for subcontractor to gain it. In a case where a consultant, subcontractor, or other third party service providers would need an access to customer data, they would go through the same training as Happeo direct employees. *In case of a change in privacy law, policy or business requirement, does* *Happeo have a process for updating its documented data protection policy,* *awareness training, and contract language with consultants, subcontractors,* *and other third party service providers?* --- Yes. We follow all data protection policies and will comply with all laws and regulations. If any of the related regulations change we are obligated to update all related documents and educate our employees and subcontractors. We will also verify that our approved and selected third party providers comply with the given laws. *In which countries will Happeo store, access, transmit or otherwise process* *customer company’s Personal Data and Sensitive Data? Which countries will* *provide Happeo services?* Happeo runs on Google Cloud Platform. The data is stored and served from inside the EEA. Some data may be transmitted and processed outside the EEA, this depends on the customer’s geographical location. *Do Happeo employees, consultants, vendors and other third party service* *providers know how and when to report security incidents?* Yes. We notify our customers from any security related event or issue immediately we have assessed the event and verified its scope. We also notify law enforcement from any security related event or issue immediately we have assessed the event and verified its scope requires law enforcement. --- **SECURITY** ## Privacy policies We respect the privacy of our customers, users and employees. As a business providing enterprise communications platforms, we need to collect, store and use data relating to our customers and our customers also use our platform for storing and using their own personal data, for instance relating to their employees. So privacy is a matter of high priority to us. We are committed to processing personal data in compliance with this privacy policy and applicable laws. This privacy policy contains information about what personal data we collect, what are the key principles of processing the data and what rights you have relating to your personal data. Through our enterprise communication platforms, we also operate from time to time as a data processor for our customers (e.g. company or organization using our solution), which means that we process personal data based on contracts on behalf of our customers in accordance with their instructions. Regarding this personal data collection and use, we advise you to read our customers’ privacy policies as well. We may do updates to this privacy policy from time to time associated with development of our business operations or changes in applicable laws, so please read visit this privacy policy from time to time. ## Data controller The data controller relating to processing of personal data pursuant to this privacy policy is: Universe Company Oy Business ID: 2802188-2 Köydenpunojankatu 2a 00180 Helsinki, FINLAND **www.happeo.com** --- Tel: +358 9 4242 5555 Email: **team@happeo.com** We can refer to Universe Company Oy in this privacy policy also as “Happeo”, “we” or “us”. It’s our responsibility to process personal data in accordance with this privacy policy and applicable privacy laws. ## For what purposes is personal data collected and used and **what is the legal basis for processing personal data?** We collect, store and process personal data only for predefined purposes. We also always make sure that there is at least one legal basis for processing personal data. The main purposes and the applicable legal basis for processing personal data are: *To provide our services. Personal data is collected and used for managing* *the entire customer relationship as well as performing our obligations and* *invoicing the services. The legal basis for this processing is a contract* *between Happeo and the customer.* --- ## Sales and marketing We also collect and use personal data for marketing purposes, including direct marketing and contacting potential customers. We may also use personal data to target or retarget advertising in digital media platforms, such as social media and search engines. The legal basis for this processing is especially our legitimate interest. A person can however at any point prohibit direct marketing by sending email to info@happeo.com. We do not sell or rent personal data to third parties for marketing purposes. ## Customer communications We also collect and use personal data for customer communication purposes, including handling of support requests and customer feedback as well as notifying users about the service. The legal basis for this processing is fulfilling contractual obligations as well as our legitimate interest. --- ## Partner co-operation We may transfer personal data about potential or existing customers to our local business partners and resellers for the purpose of handling contact requests as well as handling Happeo's sales, marketing, support and customer service locally. These partners are usually in contractual relationship with Happeo and bound by confidentiality obligations. As data controllers, they process personal data in accordance with their own privacy policies. Some of these partners may also locate outside the EU/ EEA. In such case we make sure that there are appropriate safeguards in place for the data transfer. ## Analytics and business development We also use the personal data as well as the anonymized data generated from the use of our service to develop our own digital service. The legal basis for this processing is mainly our legitimate interest. --- ## HR and recruiting Personal data relating to employees and job applicants are mainly collected and used for human resources management purposes, payment of salaries, fulfilling other rights and obligations relating to employment contracts, meeting legal requirements relating to employment as well as evaluating and selecting candidates for open positions. The legal basis for this processing may be fulfilling a contract between Happeo and the employee, consent (job applicants) as well as fulfilling legal obligations relating to employment. ## What personal data is collected and from which sources? The personal data we store relate mainly to the following groups of data subjects: potential and existing customers, potential and existing employees as well as various other roles within a customer organization, such as project team members and contract contact person. The personal data we collect and use is largely provided by the person herself. Some data is also created and generated during the use of our service. For both job candidates and potential customers we also receive personal data from external or public sources, as we constantly search both new employees and also new customers. These include companies or services such as LeedFeader, Fonecta, Dista Oy, Discover.org, and contact lists generated by virtual assistants UpWork. Regarding potential employees, we could also get information from public sources, such as LinkedIn, Monster, StackOverflow and CV boards. However, regarding job applicants and people we are interviewing we only use information provided by the applicant herself or at her consent from other sources, such as references. We also collect website use and visitor information with Google Analytics and HubSpot for analyzing our website use, develop it further and for targeting relevant marketing content for our customers and website visitors. ## Websites When you visit the Website, you are not required to provide any personal information. However, when you contact us via the chat function in the Website, when you sign up to receive information from us, or when you sign up to receive and use the Services, you are required to provide some Personal Information about yourself, and we may collect some Navigational Information, in accordance with our Cookies Policy. --- ## Personal Information “Personal Information” refers to any information that you choose to submit to us that identifies you personally. This includes, for example, your name, email address, company name, address, phone number, and other information about you and/or your business. This can also include information about you that is publicly available, information that is available about you online via sites like Facebook, LinkedIn, Twitter, and Google. In addition to other uses mentioned in this Privacy Policy, we also may use your Personal Information to: Improve your browsing experience by personalizing the Website; • Send you information we think may be of interest to you by email or other means; • Link the analytics information we store to Personal Information you submit to us; and • Contact you for marketing purposes related to our business, which we think may be of interest to you. --- ## Navigation Information This refers to information about your computer, device, visits to the Website, and logins to the Services, including your IP address, geographical location, browser type, referral source, length of visits, pages viewed, and heat mapping. We use Navigation Information to operate and improve the Website and Services, and may also use it to provide you with personalised information about Happeo Due to the nature of what is being collected, it is possible that Navigation Information may include Personal Information. ## Service Providers The Website and Services integrate some services provided by third parties. We may share some of your information with these service providers in order for them to provide their services, including removing repetitive information from prospect lists, analyzing data, providing marketing assistance, conducting customer and/or user profiling, and providing customer service. As such, the terms and privacy policies of these service providers may apply to you as well, in particular: Google Analytics, Hubspot, Intercom, Perfect Audience, GoToWebinar, Google --- Optimize, Google Adwords, Google Tag Manager, Google Recaptcha, Hotjar, Buffer and Segment. Acceptance of these service provider terms is required to access the Website and Services. Further information is set out in our Cookies Policy. Happeo seeks to conclude data processing agreements with each service provider before third party services are implemented into the Website or Services in order to ensure that your Personal Information is used, stored, and transferred securely and in accordance with European Union law. Even so, Happeo does not control or assume any responsibility for the content or practices of these service providers, including their data storage and transfer policies, and this Privacy Policy does not apply to these features, which are governed by their own policies and terms. ## External Websites The Website and Services may contain links to other websites run by third parties. Our provision of these links does not amount to our endorsement of these other websites, nor their content, owners, or practices. This Privacy Policy does not apply to those other websites, which are governed by their own terms and policies. Happeo does not control or assume any responsibility for the content or practices of these other websites. ## Customer Testimonials & Quotes We may publish customer testimonials and quotes on the Website, which may contain some Personal Information. Happeo obtains consent from each customer and the featured individual prior to posting their name and testimonial. • Data we collect and process relating to our customers: • Contact person’s name • Company name • End user profile information as provided by the customer or the user • Work email and work phone • Invoicing details • Marketing opt-in’s / opt-out’s • Email address for marketing messages • Contact details for support issues • Contact details for invoicing and executing contracts --- • and similar data. ## Data we collect and store relating to our employees: • Name and contact details • Social security number • Email • Details required for payment of salaries and withholding taxes • Health data and trade union membership data only for furthering the legal obligations relating to employment • Data we collect and store relating to our job applicants: • Basic contact details • Application and CV • With consent data from other sources, e.g. LinkedIn, references and previous colleagues or supervisors ## Data entered by the users Our customers and people within their organizations may use the entertainment communication platform for storing and processing personal data where they are considered the data controller, in these situations we operate as their data processor based on a contract. In these situation we process personal data only on behalf of the specific customer based on their instructions and only as long as we have a valid contract. More details about this processing can be found from the privacy policies our customers maintain. As a data controller, the customer has full control (and also responsibility) on what personal data it decides to enter in the platform and under what legal basis it has the right to process it and transfer to Happeo, including acquiring necessary consents, if required. Happeo does not review the data entered by the customer to the platform. For more information about under which terms Happeo processes its customer’s personal data, refer to Happeo DPA terms and conditions. ## Who processes personal data and is it transferred to anyone? Personal data is mainly stored in electronic format and only authorized personnel within our organization have access to the data. The more sensitive the data, the less people have access to it (e.g. health data related to employees). We may also use third party services providers for data storage (e.g. cloud storage), digital marketing, processing of payments and other processing of personal data. In these situations, we make sure we have a written contract with the services provider with minimum data processing provisions and also otherwise that the confidentiality of personal data is secured and data is otherwise processed and transferred lawfully. Some of these services providers include at the date of writing this policy, HubSpot, Google and Stripe. We may also disclose or transfer personal data to fulfil legal obligations or when a legal authority requires a disclosure. We may also disclose personal data if we are a party of a business sale, such as a merger or an acquisition. If any of our services providers or data transferees are located outside the EU, we make sure that the transfer of data fulfils all legal requirements. We may also transfer pseudonymised or anonymised data, from where it is not possible to identify a person. If this kind of data is no longer considered personal data, we may provide the data to third parties also for other purposes than those described in this privacy policy. ## Is personal data transferred outside the EU? By default, personal data is not transferred outside the EU. However, in varying situations data may be transferred outside the EU if our services provider is located there. --- If personal data is transferred outside the EU, we make sure that (1) the transferee is located in a country with adequate safeguards (as decided the EU commission from time to time), the (2) transferee is Privacy Shield certified (if a US-based company) or (3) the transfer occurs by using model clauses published by the EU commission. ## How long is data stored? We will not store personal data for a longer period than is necessary for its purpose or required by contract or law. The retention periods for personal data may vary based on its purpose and the situation. The retention periods may also be based on applicable laws (e.g. accounting, tax laws, employment contracts act). We may also update data from time to time. Regarding content that our customers enter into a platform we have provided, it is their responsibility to plan the data retention periods. ## How is data stored and kept secure? Personal data is stored and secured in accordance with general industry standards and practices. We consider and keep personal data confidential. Subcontractors that we use for processing personal data are selected also based on their data security measures. For our own systems and data storage, we use only well established service providers and robust software tools. Access to personal data is also protected with user-specific logins, passwords and user rights. Our premises are also safe and secure. ## Is it mandatory to provide personal data? What happens if you don’t provide it? We need to collect and process some amount of personal data in order to provide the service and to ensure that an authorized person concludes a contract on behalf of our customer, to deliver and provide the agreed services as well as to identify the registered users of our platform. Relating to employment we also need to process at least the minimum personal data required to fulfil employment contracts and legal obligations relating to employment. In recruitment situations it is not mandatory to provide us information. Everything happens on a voluntary basis. However, if you don’t provide necessary information, we may not be able to process your application. ## Does the website use cookies and what are those? We use cookies to provide our service. If you disable cookies the service wont be able to function. --- We also use cookies on our website to provide the best possible user experience for our website visitors. Cookies are small text files that are placed on a web user’s computer and are designed to hold a modest amount of data particular to a user and a website. Cookies give us information how users use our website. We may use cookies to develop our website and services, analyze website use as well as target and optimize marketing efforts. If you do not wish to receive cookies, you may set your web browser to disable them. Please note that most browsers accept cookies automatically. If you disable cookies, you should understand that our services or our website may not function correctly. ## What rights does a person have relating to her personal data? ## Access to data You have the right to have confirmed if we are processing your personal data and also to know what data we have about you. In addition, you have right to some supplemental information described in the law about the processing activities. For access requests, please contact us as instructed in the next section. --- ## Withdraw your consent If we process personal data based on your consent, you can at anytime withdraw your consent by notifying us by sending email to security@happeo.com. ## Right to have errors corrected You have the right to request that we correct any inaccurate or outdated personal data we have about you. ## Right to prohibit direct marketing You have the right to request that your personal data is not processed for direct marketing purposes by sending us email to security@happeo.com. ## Unsubscribe marketing communications You may unsubscribe from receiving our marketing communications at any time by clicking on the "unsubscribe" link located on the bottom of our emails, contacting us by email at marketing@happeo.com ## Right to object processing If we process your personal data based on public interest or our legitimate interest, you have the right to object processing of your data, to the extent that there is no such significant other reason that would override your rights or the processing is not necessary for handling legal claims. Please notice that in this situation we may not be able to serve you anymore. ## Right to restrict processing In certain situations you have the right to require that we restrict processing of your personal data. ## Right to data portability If we process your personal data based on your consent or fulfilling of a contract, you have the right to require transfer of the data you have provided to us to another services provider in a commonly used electronic format. ## How can a person use her rights? You can execute and use your rights by contacting us by sending email to security@happeo.com. In such case, we ask you to provide us your name, contact details, phone number as well as something that we can use to verify your identity, such as written and signed (and scanned) request, or a copy of your personal ID, but without social security number and other such information that we don’t need. If you consider that the processing of your personal data is not lawful, you can always also make a notification to a supervisory authority (in Finland tietosuojavaltuutetun toimisto). ## Can this privacy policy be updated? We may make updates to this privacy policy when our operations change or develop. Also changes in law may make it necessary to update this privacy policy. The changes become valid once we have published them in the form of an updated privacy policy. Therefore, please visit this page and read this privacy policy from time to time. --- happeo